Thursday, November 14, 2013

Patterson v. McClean Credit Union case brief

Patterson v. McClean Credit Union case brief summary
491 U.S. 164, 109 S. Ct. 2363, 105 L. Ed. 2d 132 (1989)


CASE SYNOPSIS: Petitioner employee sought a writ of certiorari from a judgment of the United States Court of Appeals for the Fourth Circuit, which affirmed the decision that her racial harassment claim against respondent employer was not cognizable under 42 U.S.C.S. § 1981 and that, in her discrimination claim, she had to prove she was better qualified than the white employee who was promoted in her stead.

CASE FACTS: The employee sought damages for racial harassment and for discrimination under 42 U.S.C.S. § 1981. 

DISCUSSION
  • The Court held that harassment relating to the conditions of her employment was not actionable under § 1981 because, under the rule of stare decisis, that provision did not apply to conduct that occurred after the formation of the contract and did not interfere with the right to enforce established contract obligations. 
  • With the exception of the refusal to promote claim, none of the conduct that petitioner alleged was racial harassment involved either a refusal to make a contract or the impairment of her ability to enforce her contractual rights. 
  • However, the failure to promote was actionable under § 1981 because it involved her ability to enter into a new contract with her employer. 
  • The appeals court erred in holding that the employee could succeed in her discriminatory promotion claim only by proving that she was better qualified for the position than the white employee who was promoted. 
  • The employee was not limited to presenting evidence of a certain type in order to demonstrate that the employer's proffered reasons for its decision were not its true reasons.
CONCLUSION: The Court affirmed the dismissal of the employee's racial harassment claim as not actionable under § 1981. The Court vacated the decision insofar as it related to petitioner's discriminatory promotion claim and remanded the case for further proceedings.

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